Training document. This compliance binder, the company it belongs to, its people, its vendors, its incidents and every figure in it are fictional. The laws it cites — MiCA, DORA, the Transfer of Funds Regulation and the AML instruments — are real, cited by article as they stood in 2026, and simplified for teaching: a real firm's policy set is longer, runs to the technical standards beneath each article, and turns on its own regulator's expectations. Nothing here is a template for use. Copper chips like Explained in Ch. 9 link each section to the chapter that explains it.

VERSION 3.1 · APPROVED BY THE BOARD 12 NOVEMBER 2025

Compliance Binder — extracts

HALCYON DIGITAL ASSETS LIMITED
crypto-asset service provider authorised by the Central Bank of Ireland
owner: Head of Compliance · next review 12 November 2026

§Contents

§What this binder isExplained in Ch. 1

§1This binder holds the policies Halcyon Digital Assets Limited (“Halcyon”) keeps because the law requires them: MiCA (Regulation (EU) 2023/1114, the EU rulebook for crypto-assets), DORA (Regulation (EU) 2022/2554, on technology resilience), the Transfer of Funds Regulation and the anti-money-laundering (AML) instruments. Halcyon, incorporated in Ireland on 9 June 2021, was authorised by the Central Bank of Ireland (the “Central Bank”) as a crypto-asset service provider on 12 November 2025.

§2Version 3.1, approved by the Board 12 November 2025; owner the Head of Compliance; next review 12 November 2026. A policy changes only by Board resolution; the Head of Compliance records each change and circulates it to all staff. Amendments recorded since approval: 20 January 2026, paragraph 1.4 and the host-state line of Appendix B; 30 June 2026, Appendix C; 1 September 2026, paragraph 1.6 and Appendix B.

§3Article numbers without a regulation named are MiCA's, except in Policy 7, where they are the Transfer of Funds Regulation's, and in Policy 9 and Appendix C, where they are DORA's; “business day” means a day banks in Dublin are open. Where a rule turns on a national choice or technical standards, the binder gives the position at the time of writing (2026).

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